Tribunal Criminal Tribunal for the Former Yugoslavia

Page 10415

 1                           Tuesday, 26 August 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 9.03 a.m.

 6             JUDGE DELVOIE:  Good morning to everyone in and around the

 7     courtroom.

 8             Madam Registrar, could you call the case, please.

 9             THE REGISTRAR:  Good morning, Your Honours.

10             This is the case IT-04-75-T, the Prosecutor versus Goran Hadzic.

11             JUDGE DELVOIE:  Thank you.

12             May we have the appearances, please, starting with the

13     Prosecution.

14             MR. STRINGER:  Good morning, Mr. President, Your Honours.  For

15     the Prosecution, Douglas Stringer, Sarah Clanton, Case Manager

16     Thomas Laugel, legal intern Marina Marcikic.

17             JUDGE DELVOIE:  Thank you.

18             And for the Defence, Mr. Zivanovic.

19             MR. ZIVANOVIC:  Good morning, Your Honours.  For the Defence of

20     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell.  Thank you.

21             JUDGE DELVOIE:  Thank you.

22             Mr. Hadzic, I remind you that you are still under oath.

23             Mr. Stringer, please proceed.

24             MR. STRINGER:  Thank you, Your Honour.

25                           WITNESS:  GORAN HADZIC [Resumed]

 


Page 10416

 1                           [Witness answered through interpreter]

 2                           Cross-examination by Mr. Stringer: [Continued]

 3        Q.   Good morning, Mr. Hadzic.

 4        A.   Good morning.

 5        Q.   To start with this morning, I'd like to go back to an exhibit we

 6     looked momentarily yesterday, which is Exhibit 1D03600, and the

 7     tab number for that I failed to note.

 8                           [Prosecution counsel confer]

 9             MR. STRINGER:  97.

10        Q.   This is the newspaper article we looked at yesterday, and you

11     weren't able to find the relevant part of the text that I was wanting to

12     discuss with you in the original language version, and I think it turns

13     out that actually if we just go to the next page of the B/C/S version, we

14     will find what we're looking for.  That's it.  So that was my mistake.  I

15     just forgot to take you to the next page.

16             So this -- and, again, we're still on the subject of

17     Mr. Stevo Bogic.  This is from the 16th of July, 1991, the Danas

18     publication.  And does it now appear to you, Mr. Hadzic, that the B/C/S

19     text that you can read corresponds to the English translation, if you're

20     able to say that.  This is an article entitled:  "No talks with the

21     Croats."  And then it starts off:

22             "In Borovo Selo, since the clashes in May, no journalists from

23     the north-west have been in Borovo Selo ..."

24             Do you see that?

25        A.   Yes, yes, I see that.


Page 10417

 1        Q.   All right.  And in that first paragraph there, there are some

 2     words attributed to Mr. Bogic, and he says there that Croatian

 3     authorities had issued several wanted notices against him, and they were

 4     just waiting for Serbia to recognise as its own territory Slavonia,

 5     Baranja, and Srem.  He goes on to say that:

 6             "Too many insults, too many victims fell, so living together is

 7     no longer possible."

 8             This being in July, Mr. Hadzic, I understand from your earlier

 9     testimony that during this period you were actually spending time living

10     in Borovo when you were unable to get to your home town of Pacetin

11     because of the roads.  Is that correct?

12        A.   Well, no, you didn't understand that quite right.  I did not live

13     in Borovo at the time.  I didn't have anyone to stay with.  I was in

14     Borovo Selo sometimes once a week or once every two weeks, I spent two or

15     three hours there.  I didn't live there at the time.  That's not where I

16     slept.  I was with my family in a village near Sombor, and all of a

17     sudden, I simply cannot remember the name of that village where we were

18     staying.

19        Q.   Okay.  And on the transcript from July 8th, on page 9534 to 9535,

20     your counsel asked you -- first of all, he is asking you:

21             "Where did you spend your time.  Did you live in Slavonia,

22     Baranja, and Western Srem all the time or did you live in Serbia, like in

23     May 1991?"

24             You said, this was your answer:

25             "My family were refugees in Serbia and I usually return in the


Page 10418

 1     evenings and spent the night with them.  During the day I spent most of

 2     my time in Borovo Selo.  And if I was able to find a car, sometimes I

 3     would go to Pacetin."

 4             So maybe my question wasn't the best one.  So the question now

 5     would be:  During, say, this period of May, were you spending a good

 6     portion of the day in Borovo Selo?

 7        A.   Well, I came to Borovo Selo only in the second half of the first

 8     half of May.  That would be after the 10th of May.  And then on the

 9     15th of May, again I tried.  That's when Vula drowned.  What I said has

10     to do with the second part or the end of May.  That is to say that I

11     would spend the day there, but I would not spend the night there.  I

12     mean, your question, the one that has do with this text, I thought that

13     that related to July.

14        Q.   Right.  We're going to get there.  And actually we'll go there

15     with my next question because again referring back to your direct

16     examination, Mr. Zivanovic asked you if you remembered journalists and

17     reporters making a visit to Borovo, both foreign and domestic press, in

18     those days of July 1991.  And your answer was yes, you did remember that,

19     and that you sometimes had occasion to meet with them.  Do you remember

20     that testimony?

21        A.   Yes, I remember, and that's the way it was.

22        Q.   And then actually what followed, then, was you were asked to

23     comment on a different newspaper article which is now already in

24     evidence, which is D118, which was the 13th of July article in the

25     Politika.  And so I would just want to ask you now about this other


Page 10419

 1     exhibit that we see, 3600, which is three days later now on the

 2     16th of July, 1991.

 3             So does this article also refer to that period you just were --

 4     had described earlier about when you had an opportunity to speak to

 5     journalists who had come to Borovo Selo?

 6        A.   You mean this article that's on the screen now?

 7        Q.   That's right.  We can go down to the second paragraph and you'll

 8     see that there are some statements there that are attributed to you.

 9        A.   I'd have to see that first in order to be able to answer your

10     question.  I just need a minute or two.

11        Q.   It's the paragraph that begins with the words:

12             "Instead of having a national council, Slavonia, Baranja, and

13     Western Srem have, since recently, had their own government."

14             JUDGE DELVOIE:  Mr. Zivanovic.

15             MR. ZIVANOVIC:  Sorry, but none of the paragraphs in B/C/S begins

16     with these words.

17             MR. STRINGER:

18        Q.   Mr. Hadzic, in the article, do you see a quote -- well, do you

19     see a reference to what I've just described even if the words aren't

20     exact.  A reference to instead of having a national council, SBWS now has

21     a government, Hadzic as its president, says that its first task is for

22     these areas to be joint to Serbia as soon as possible.  And then it goes

23     on to refer to Mr. Devetak.

24             JUDGE DELVOIE:  Yes, Mr. Zivanovic.

25             MR. ZIVANOVIC:  Sorry, if this question could be put after the --


Page 10420

 1     Mr. Hadzic read complete article.  He was asking the time to read this --

 2     this article from the screen.

 3             MR. STRINGER:  That's right.  I apologise, I was simply trying to

 4     direct Mr. Hadzic to the part that I'm interested in, but if he wants to

 5     take more time to read it, that's fine.

 6              I see that it's in Latin script.  It would be the second

 7     paragraph of the original language version.  I believe.

 8             THE WITNESS: [Interpretation] Yes, yes, I see it and I've read it

 9     just now.  I did not give that statement.  I see that these are Croatian

10     journalists.  I did not give any statements for the Croatian press at

11     that time.  And he's not quoting me.  This journalist is giving his own

12     comment.  But if I understand this properly, he talked to Vitomir Devetak

13     and Stevo Bogic, not me, and I'm not even sure that he talked to them.

14     That's the way it looks on the basis of what has been written here.

15             JUDGE DELVOIE:  Can we have the next page in English, please.

16     Thanks.

17             MR. STRINGER:

18        Q.   Well, let's do this, Mr. Hadzic.  I don't want to spend too much

19     time on this.  But let's look at the words of Mr. Devetak here.  In that

20     paragraph it says:

21             "Vitomir Devetak, who held a press conference in a domestic and

22     foreign journalists in an abandoned school hall, believes that Serbia is

23     hesitant."  And then it goes on.

24             He refers to:

25             "56 villages from Slavonia, Baranja, with a Serbian population


Page 10421

 1     are tied to Borovo."

 2     Do you see that?

 3        A.   I do.

 4             MR. STRINGER:  Could we please have D118, which is the article

 5     from the 13th of July that came into evidence during Mr. Hadzic's direct

 6     examination.  I don't have a tab number for that.

 7        Q.   Now, this is an article that you looked at on your direct exam,

 8     Mr. Hadzic, and that you then -- that was then put into evidence.  I'd

 9     like to direct your attention under the -- first of all, if we could blow

10     it up.  This is the article called:  "A place of men, impressions of

11     foreign journalists."  And the second section of it is under the heading:

12     "Peaceful separation."  And I know it's small text.  If we could find a

13     way to blow that up.  I can also give you my hard copy, if you'd like,

14     although it's small text.

15        A.   Yes, I remember you gave it to me last time as well.  And, again,

16     the print was very fine, and I couldn't see.

17             Could they just blow up that part of the text?  A bit more, to

18     the right.  Now they should scroll down.  Yes.

19        Q.   The article begins:

20             "Borovo Selo, July.  The cease-fire, the hardest one, which is

21     only apparent, has lasted for a few days ..."

22             Do you see that?

23        A.   I can't read any of this that is written here.  Actually, I can

24     read half of it, and I cannot read the other half.

25        Q.   Why are you unable to read the other half?  I don't recall you

 


Page 10422

 1     had any difficulty reading this when it was shown to you on direct

 2     examination, sir.  That's when I'm asking.

 3        A.   When I said I can read half of it, I don't mean exact halves.  I

 4     can read one letter and then I cannot read another one, so in a sentence,

 5     I can read, say, half a word.

 6        Q.   Okay.  Well, we'll just make a large copy of it, and we'll come

 7     back to this a third time and see if we can make it work, Mr. Hadzic.

 8        A.   [In English] Okay.

 9             MR. STRINGER:  Now, could we please have tab 1420, and this is an

10     under-seal document.

11                           [Trial Chamber confers]

12             JUDGE DELVOIE:  Yes, Mr. Stringer.

13             MR. STRINGER:  Tab 1420.  It is P1382.1351.  It's under seal.  So

14     perhaps we should go into private session.  Although, if we don't

15     broadcast it, Mr. President, perhaps -- well, I think to be safe, if we

16     could go into private session.

17             JUDGE DELVOIE:  Let's go into private session, to be on the safe

18     side.

19                           [Private session]

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)


Page 10423

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11 Pages 10423-10425 redacted. Private session.

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Page 10426

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9                           [Open session]

10             THE REGISTRAR:  We're in open session, Your Honours.

11             JUDGE DELVOIE:  Thank you.

12             MR. STRINGER:

13        Q.   This is minutes of the District Council of the SBWS meeting held

14     in Erdut on 6th of July, 1992.  And here we see present are members of

15     the District Council.  This is Milan Ilic.  We've talked about him.

16     Pajo Nedic.  I asked you about him yesterday.  Other members of the

17     district council.  And then other people present, Jovo Rebraca.  Who is

18     he, Mr. Jovo Rebraca?

19        A.   Rebraca was president of Tenja municipality at that time.

20        Q.   Djordje Calosevic, who was he?

21        A.   He was president of Dalj municipality.

22        Q.   Was he also a member or did he hold a leadership position in the

23     SDS?

24        A.   He was not a leader.  I believe he was a member of the SDS.  But,

25     at that time, there was a moratorium on the work of political parties.

 


Page 10427

 1     The SDS was not active.

 2        Q.   And then then moving down, we see that Stevo Bogic now is

 3     attending this meeting.  Do you know whether it was -- whether as part of

 4     his duties as deputy prime minister, Mr. Bogic would have been attending

 5     meetings like this, things happening at the more local level as opposed

 6     to the federal level or the republican level?

 7        A.   I don't know whether it was his duty.  I don't think so under the

 8     constitution.  You asked me yesterday what his title was but I saw it

 9     now.  You saw he was at that meeting with Vejzovic.  He co-ordinated the

10     work and helped the prime minister, so that's how we can see what his job

11     was.  But at that time I didn't know.

12        Q.   So that here he would be acting as a representative of the

13     prime minister at this district council meeting?

14        A.   I'm just guessing.  I really know nothing about that session.  I

15     didn't know when it was being held.  I'm seeing this for the first time.

16        Q.   Did you have a personal or friendship relationship with

17     Mr. Djordje Calosevic?

18        A.   Not really.  I knew him, but I did not have any particular

19     relationship?

20        Q.   Did you -- did he ever accompany you to meetings or to social

21     functions?

22        A.   He never went to meetings together with me, but he did attend

23     some meetings.  Not really accompanying me.

24        Q.   What about social functions, either during this period or later?

25        A.   I don't remember that.  There were a lot of developments and


Page 10428

 1     events, but I don't remember whether Calosevic was there or not.

 2             MR. STRINGER:  Mr. President, we tender 65 ter 6532, the minutes

 3     of this District Council meeting.

 4             JUDGE DELVOIE:  Mr. Zivanovic.

 5             MR. ZIVANOVIC:  I would object because the witness doesn't know

 6     anything about this meeting and this document -- particular document and

 7     there is no foundation for admitting this document into evidence.

 8             JUDGE DELVOIE:  Mr. Stringer.

 9             MR. STRINGER:

10        Q.   Mr. Hadzic, can you go to the last page of the original?

11             MR. STRINGER:  If we could go to the last page of the original

12     language version.

13        Q.   Whether you recognise the stamp and/or the signature?

14        A.   I see this stamp for the first time.  It must be the new stamp of

15     the District Council.

16             Yesterday you asked me about Milan Ilic's signature.  I saw it

17     for the first time yesterday, but this is completely different.  It's not

18     the same thing as the one yesterday.  I don't know who signed this.

19        Q.   Well, this is Mr. Jovan Jovicic, I believe.  That's what the

20     translation indicates.

21        A.   He was a member of the technical staff.  I never heard that name.

22     I never heard that he occupied any position.

23        Q.   What do you mean by "technical staff"?  Like, was he a secretary

24     or an administrator?

25        A.   I'm not sure that that this is really "Jovan Jovicic" written


Page 10429

 1     here.  Jovan Jovicic did not exist in an important position.  I think he

 2     was an unimportant person.  I don't know exactly what the name is, Jovan

 3     Jovicic or Jovic.  I don't know whose signature this is.

 4        Q.   Mr. Hadzic, we don't disagree, do we, that during this period of

 5     time Mr. Milan Ilic was the president of the District Council for SBWS;

 6     is that correct?  We can agree on that?

 7        A.   I've said that at least ten times.  From spring 1992 he was

 8     elected the -- the elected president of that District Council.

 9        Q.   And just on that, as the president of the District Council did he

10     sort of -- was he the leading executive, the leader of the executive body

11     for SBWS then?

12        A.   Well, by the very name of that title, that's what it means.  But

13     I didn't meddle in their work, and I don't know to what extent they made

14     any decisions.

15        Q.   I've just been informed that I misspoke, I said "Jovan" and I

16     should have said "Nemanja," I think, which is the name as it appears on

17     the translation.  Nemanja Jovcic.  Do you know who that is, Mr. Hadzic?

18        A.   I saw that he was at the meeting.  I personally didn't know him.

19     Now I see that it's not Jovicic by Jovcic, first name Nemanja.  I don't

20     know what his position was.

21             MR. STRINGER:  Could we please have tab 63, 1D03460.

22             This may be a confidential document, Mr. President.  If we could

23     not broadcast, I think I can work with that.

24             JUDGE DELVOIE:  Okay.  Thank you.

25             MR. STRINGER:


Page 10430

 1        Q.   Mr. Hadzic, the first part of this document, the first page, and

 2     by the way, just for the record, this is dated -- we're jumping ahead in

 3     time now to the 24th of May, 1994.

 4             And this is a report of some -- of an event that took place on

 5     the 21st of May and it refers to Mr. Seselj attending a meeting of SRS,

 6     Serbian Radical Party representatives in Borovo Naselje.  I actually am

 7     going to skip over that part because it's not what is of interest here.

 8             MR. STRINGER:  If we could go to page 2 of the English version.

 9     In the B/C/S version, it's the last paragraph of the document.

10        Q.   And it refers to the village feast day in Pacetin.  At this time,

11     you're the former president of the RSK.  You had organised a party.  Take

12     a look at that, Mr. Hadzic, and tell us if you remember that?

13        A.   I don't remember that celebration of the patron saint's day

14     specifically.  There were many people there.  I don't remember exactly.

15        Q.   It is indicated here that Mr. Bogic attended this event as well

16     as Mr. Djordje Calosevic, Boro Bogunovic.  The party was festive, there

17     was a band.  And also there's a reference to Mr. Misa Milosevic who was

18     present.  And on him, Mr. Misa Milosevic, his name has come up before in

19     connection with your participation in the international negotiations,

20     correct?  He accompanied you and Mr. Babic, I believe, in some of the

21     early negotiations with Mr. Wijnaendts and the Carrington Commission.  Is

22     that true?

23        A.   It's true we mentioned Misa Milosevic.  At that time when we

24     mentioned him, that was the autumn of 1991, I didn't know him.  He was in

25     a delegation of the SAO Krajina headed by Milan Babic.  That's when I


Page 10431

 1     first heard of him, and I met him a bit later.

 2        Q.   Do you remember him attending a party that you hosted in your

 3     village, the event that's referred to here?  Do you remember this?

 4        A.   I remember.  Misa was in Pacetin only once, together with

 5     Momo Kapor.  But, for instance, a person, Djuro Kljajic is mentioned

 6     here.  I don't know such a person so he couldn't ever have been in my

 7     house.  Nobody with that name has ever visited me.  But I cannot say

 8     about these names that they were either there or not because there were

 9     over 50 people there, coming and going.

10        Q.   Mr. Bogic has been a guest in your house, I take it?

11        A.   In Pacetin very rarely.  I don't remember that he was ever in

12     Pacetin.  But I should like to tell the Trial Chamber, in the Serbian

13     Orthodox religion, you don't invite people to your patron saint's day.

14     People who know who are your friends will come on their own.  There were

15     some people who came from Belgrade, from a long way away, and the rest

16     were locals.  But none of them were specifically invited.  You don't

17     invite people, that's our custom.  You don't invite people on that day.

18     They come on their own.

19        Q.   And Mr. Djordje Calosevic, he has also been a guest in your

20     house, whether on this occasion or other occasions; correct?

21        A.   Earlier when I was the president of the republic, he didn't come.

22     And later, when I lost the elections, I don't know why he would come

23     then.  Maybe he had come earlier to congratulate me, to express his

24     support.  But I really don't remember.

25             MR. STRINGER:  Could we please have tab 1014.  This is a


Page 10432

 1     video-clip.  And it is 65 ter 4811.4, and we'll wait for the interpreters

 2     to let us know when they've found it.

 3             While we're waiting for the interpreters, Mr. President, I have

 4     just been informed by my colleague Ms. Clanton that the document we just

 5     looked at a moment ago, 1D03460, is a public exhibit from the

 6     Stanisic-Simatovic case, and so it may not be necessary to have

 7     confidential status linked to this document for our case.

 8             THE INTERPRETER:  We have it.

 9             JUDGE DELVOIE:  Okay.  So we can lift that status.

10                           [Video-clip played]

11             THE INTERPRETER: [Voiceover] "Dafina Milanovic with her

12     associates visited Baranja and Srem today.  Stevo Bogic, deputy prime

13     minister of the Republic of Serbian Krajina; Milan Ilic, president of the

14     District Council of the Serbian District; Zeljko Raznjatovic, Arkan,

15     commander of the Serbian Volunteer Guard; and a group of businessmen from

16     the district welcomed her in Erdut.  During her meeting, Mrs. Milanovic

17     inquired about the economic situation and possibilities to invest in the

18     revival of economy.  She said that the possibilities and potential of the

19     district are huge and the potential of Krajina has to be used in a proper

20     way for the benefit of the people, Serbian Krajina, and its future.

21             "Dafina Milanovic:  I believe we could make it become better than

22     Switzerland.  Having in mind the potential of Krajina, it would be easy

23     to achieve if we start to work more and if we show more responsibility.

24     The situation will get better once we start employing people.  It is my

25     intention first to build a greenhouse, to start producing food because


Page 10433

 1     that's what is most needed in Serbian Krajina.  Then we would start with

 2     livestock farming.  I talked yesterday with businessmen from Thessaloniki

 3     and Athens about investments in the livestock export industry here as

 4     well, as well as a dairy plant, and I think we will start working on it

 5     very soon.

 6             "Another speaker:  If Mrs. Dafina is of the opinion that our area

 7     could become ... we have no reason to doubt it.  It is our duty to work

 8     on it and make it happen."

 9             MR. STRINGER:

10        Q.   Well, we'll take another look at the video, Mr. Hadzic, but just

11     the very last person who was speaking, can you tell us who that was?

12        A.   Milan Ilic.

13        Q.   Okay.  Let's start the video again and we'll stop at a couple of

14     places.  I'm going to ask you to identify some more people.

15                           [Video-clip played]

16             MR. STRINGER:

17        Q.   Now, and before we go further, Mr. Hadzic, I should ask, can you

18     tell us who is this woman, Dafina Milanovic?

19        A.   She had a privately owned bank, as far as I remember, in

20     Belgrade.

21        Q.   And can you identify the two men who are then on either side of

22     her, holding the flag, in the image that we're just looking at here.

23        A.   On the right of her, as you all well know, is Zeljko Raznjatovic,

24     Arkan, and to her left, I can identify Milan Ilic.

25        Q.   What period of time was Mr. Ilic - if you know - the president of


Page 10434

 1     the SBWS District Council?

 2        A.   I don't know exactly.  I know it was from spring 1992 until --

 3     I'm not sure when.

 4        Q.   Why did he wear a uniform if is he a civilian, holding down a

 5     civilian position as president of the District Council?

 6        A.   You can ask me -- you're asking me too much as a witness.  From

 7     my information, I never heard why he was wearing a uniform.  Milan Ilic

 8     is dead, by the way.

 9        Q.   At the beginning of your cross-examination before the summer

10     recess when we were talking about Arkan I showed you an exhibit which was

11     P1909, in which a reference was made to Ilic being fond of wearing the

12     Tigrovi uniform.  Do you remember that?

13        A.   I remember you said that, but that was the first time I heard

14     about it.  I didn't know it.

15        Q.   Well, what we see here is -- from what we can see, it appears he

16     is wearing something very similar to the Arkan that -- to the uniform

17     that Arkan is wearing, isn't he?

18        A.   I can't say that.

19             MR. STRINGER:  If we could just roll the video for a little bit

20     more.

21                           [Video-clip played]

22             MR. STRINGER:  Okay.

23        Q.   Just for the record, Mr. Hadzic, who are we looking at here?

24        A.   Stevo Bogic.  In the centre.

25        Q.   And in the footage, he's introduced as deputy prime minister of


Page 10435

 1     the Republic of Serbian Krajina, so this would at least be sometime in or

 2     after the spring of 1992; correct?

 3        A.   1992/1993.  I really don't know exactly when it was.

 4             MR. STRINGER:  Mr. President, we tender this clip, 65 ter 4811.4.

 5             JUDGE DELVOIE:  Admitted and marked.

 6             THE REGISTRAR:  As Exhibit P3224, Your Honours.

 7             JUDGE DELVOIE:  Thank you.

 8             MR. STRINGER:  Could we please have tab 1720.  65 ter 6562.  It's

 9     a confidential document, which I think -- if we don't broadcast it on the

10     screens outside, I can manage.

11        Q.   This is a report, Mr. Hadzic, dated 13th of October, 1993.  It's

12     coming from Belgrade.  It's referring to a session of the Assembly of the

13     SBWS that was held in Dalj on the 11th of October.  And then another

14     session that was held the following day, on the 12th of October, in

15     Vukovar.  And at that session, Deputy Stevo Bogic and Boro Bogunovic

16     forced and pressured deputies who wanted to go to the continuation of the

17     session at Plitvice, saying they would not get there.

18             Take a look, take a moment to look at the document, Mr. Hadzic,

19     because --

20             JUDGE DELVOIE:  Yes, Mr. Zivanovic.

21             MR. ZIVANOVIC:  Your Honours, I would kindly ask that this

22     document Mr. Hadzic could read in its entirety because it is just

23     recently disclosed, and I don't believe that he had the opportunity

24     earlier to see that at all.

25             MR. STRINGER:  I can give him my hard copy, Mr. President, if


Page 10436

 1     that would assist.

 2             JUDGE DELVOIE:  I think that would.  Thank you, Mr. Stringer.

 3             THE WITNESS: [Interpretation] If you're asking me about this

 4     document, I think it's a pamphlet infiltrated at the beginning of the

 5     election campaign in the Republic of Serbian Krajina.

 6             MR. STRINGER:

 7        Q.   It -- what is -- what I'm not interested in is the -- if there is

 8     sort of some political competition that is taking place between you and

 9     Mr. Martic, his people and your people, we're not interested in that.  We

10     see that this is in the leadup to the election that occurred in

11     December of 1993.

12             The question I have, though, is at the bottom of the last

13     paragraph on the first page of the English version, which begins with the

14     words:

15             "In the process, the citizens do not believe all these statements

16     because they know ..."

17             Do you see that?

18        A.   On the second page in Serbian.  Now I see it.  I have it in my

19     hands.

20        Q.   And actually in the preceding paragraph there's a reference here

21     in this report to a statement that's attributed to you that:

22             "Slobodan Milosevic has been informed of everything, that Hadzic

23     is in daily contact with him, along the lines of:  I agreed on this too

24     with Slobo a moment ago."

25             And then it goes on to say:


Page 10437

 1     "In the process, citizens do not believe all these statements because

 2     they know that actually in question is an attempt of a group of

 3     criminals, headed by President Hadzic, Steve Bogic, Boro Bogunovic,

 4     Vukasin Egic, Jovan Rebraca and others, to retain a monopoly over the

 5     material goods of the [sic] region."

 6             And then it continues on.  We can all read that.

 7        A.   It's important also to read that the Socialist Party of Serbia is

 8     also mentioned.  That says it all about this text.  And it shows the

 9     purpose of this text.  The target audience.

10        Q.   Well, in fact, in the video-clip that we just saw where

11     Mr. Bogic, Arkan and Ilic and all the businessmen were meeting with

12     Ms. Milanovic, there was an objective of acquiring control over the

13     material wealth of that region, the SBWS, and people who'd been with you

14     from the beginning, such as Stevo Bogic and Arkan, were a big part of

15     that.  Isn't that true?

16        A.   Well, I'm a bit stunned by your logic and linking this document

17     to what we were discussing and the visit of Dafina Milanovic in Erdut.

18     First of all, I think that has nothing to do with it.  And secondly,

19     during the war, in the former Croatia, there was a lot of crime on both

20     sides, the Croatian side and the Serb side.  And there's no denying that.

21     Dafina Milanovic came only once.  I don't know anything about that.  And

22     now whether Arkan was involved in crime or somebody else, I really don't

23     know.  The judiciary hasn't said anything about it so I can only make

24     assumptions.

25             MR. STRINGER:  Could we please have tab 1037.


Page 10438

 1        Q.   We're going to change gears here, Mr. Hadzic, take on a new

 2     topic.

 3             MR. STRINGER:  This is a video-clip.  65 ter 4873.2.  And we'll

 4     wait for the interpreters --

 5             THE INTERPRETER:  We have found it.  Thank you.

 6                           [Video-clip played]

 7             THE INTERPRETER: [Voiceover] "Anchor:  As previously announced,

 8     Goran Hadzic, president of the Serb region of Slavonia, Baranja, and

 9     Western Srem is in our studio.  Good evening.

10             "Goran Hadzic:  Good evening.

11             "Anchor:  When did you arrive in Belgrade?

12             "Goran Hadzic:  Well, I arrived last night.

13             "Anchor:  Can I ask you as a reporter what the current situation

14     in the war theatre is?

15             "Goran Hadzic:  Well, the situation is much clearer in military

16     terms.  We have a big part of free liberated territory in our area.  That

17     is, the whole of Baranja, Western Srem, from Vinkovci in the direction of

18     Sid, and the bigger part of this Osijek field.  That is, the territory

19     between Osijek and Vukovar.  Vukovar is currently blocked.  We expect a

20     denouement of the situation in Vukovar any day.  We are capable of

21     dealing with this quickly, but we are thinking of human lives and taking

22     care that this would be done slowly and securely with as little

23     casualties as possible.  That is, we do not want any casualties."

24             MR. STRINGER:

25        Q.   Before we continue, Mr. Hadzic, based on your description of the


Page 10439

 1     situation here, Vukovar is still blocked, this would indicate to us that

 2     we're talking about the period obviously prior to the 18th of November,

 3     1991, sometime perhaps in earlier November, October 1991 [Realtime

 4     transcript read in error "1992"].  Is that generally the time-frame here,

 5     based on what you've said?

 6        A.   Well, I think it could be that, yes.

 7        Q.   Now, the information that you're sharing with the reporter here,

 8     who was briefing you on the military situation, status, operations

 9     objective, what was the source of your information that you're giving us

10     here?

11        A.   I think I've already explained this to you maybe once.  I gave

12     information on the basis of the knowledge I had as an ordinary citizen

13     and from the media and -- I had the opportunity of buying newspapers in

14     Serbia.  In Slavonia and Baranja, people could not read the newspapers or

15     see the electronic media.  Also I got information from friends, some

16     ministers at meetings, et cetera.  It was unofficial but I didn't want to

17     say on TV that I did not know because in this way, I would do away with

18     my political position.

19        Q.   You just said you "had the opportunity of buying newspapers in

20     Serbia.  In Slavonia or Baranja, people could not read the newspapers or

21     see the electronic media."

22             So are you telling us that all of the information you got about

23     what was happening was coming to you from the newspapers in Belgrade?

24        A.   Well, I don't know whether this interpretation is good, what I

25     said just now.  I think that you've misquoted me just now.  Perhaps it's


Page 10440

 1     a mistake in the transcript, so I'm going to repeat what I said.

 2     I said that in Slavonia and Baranja there weren't any newspapers and

 3     there wasn't any television.  People couldn't watch television because

 4     there usually wasn't electricity.  And I bought newspapers in Serbia.

 5     When I was in Serbia, I could see the Belgrade media and the Zagreb media

 6     and I even found a way of obtaining Croatian newspapers, too, so I got

 7     information from both sides, the Serb and the Croat sides. Because I had

 8     to be very careful about this.  I didn't have a particular service, a

 9     police or military police that would inform me, so that was the only way

10     in which I received information, the way I described just now, through

11     Croatian and Serbian media and a bit through foreign media. But my

12     English was not at that level that I could understand 100 per cent of

13     everything, so it was mostly the Serbian media and the Croatian media.

14        Q.   So you read in the Serbian media or in the media that denouement

15     on the situation in Vukovar could come any day?

16             JUDGE DELVOIE:  Mr. Zivanovic.

17             MR. ZIVANOVIC:  Sorry, I notice that one word was omitted from

18     the transcript.  In -- at page 25, line 8, after the word "a police or

19     military" -- the word "military" was omitted.

20             THE WITNESS: [Interpretation] Yes, I said that I did not have

21     that kind of service.  I did not have a police or a military.

22             JUDGE DELVOIE:  Please proceed, Mr. Stringer.  It's on the record

23     now.

24             MR. STRINGER:  Thank you, Mr. President.  Also I think either I

25     misspoke or there was a mistake on page 24, line 6, I was suggesting to


Page 10441

 1     Mr. Hadzic that this was sometime prior to 18th of November, 1991, and

 2     then I said sometime perhaps in earlier November or October 1992, and

 3     that obviously actually should be 1991.

 4             JUDGE DELVOIE:  Thank you, Mr. Stringer.  It's on the record now.

 5             MR. STRINGER:

 6        Q.   Mr. Hadzic, you were going to Belgrade frequently.  We know that

 7     during the fall of 1991 you were meeting with people in the Ministry of

 8     Defence.  We're going to talk about your meeting with Mr. Mandaric in a

 9     little while in Novi Sad.  The fact is, you were getting your information

10     not from the press but from military and political people whom you were

11     meeting throughout this period of time.  Why don't you just admit that?

12        A.   Why would I admit that when that is not true?  I'm not being

13     forced to say something in terms of admitting or not admitting.  I'm

14     testifying here.  I'm not here to admit this or that.  I'm testifying

15     about what things were like.

16             As for the people you mentioned, they actually asked me about

17     what was going on there, specifically Mandaric and the Defence Ministry,

18     and they didn't know anything what was going on over there.  They knew

19     even less than I did.

20        Q.   So when you are saying things like:  "We expect denouement of the

21     situation in Vukovar any day, we are capable of dealing with this

22     quickly, we are thinking of human lives," this is all just stuff you are

23     making up?  I mean, you wouldn't be reading about that in the press, I

24     don't think.  Is this just a political statement you're making?

25        A.   Well, you could interpret it any which way you want but that was


Page 10442

 1     my conclusion.  This was my sublimation of this situation and that is

 2     what I wanted to say in public, so you can say that I made it up or that

 3     I provided information halfway or whatever.

 4             MR. STRINGER:  We're continuing with the video but I'm not

 5     hearing any interpretation.

 6             THE INTERPRETER:  We cannot hear anything.

 7                           [Prosecution counsel confer]

 8                           [Video-clip played]

 9             THE INTERPRETER:  We just heard half a second of the soundtrack

10     now, interpreter's note.

11                           [Video-clip played]

12             THE INTERPRETER: [Voiceover] "Anchor:  Do you have information on

13     events in Vukovar?  Do you have information on Serb people in Zagreb?

14     All communication lines are down, there is no phone connection, people

15     cannot talk to their families.

16             "Goran Hadzic:  As I said, I'm not concerned with military

17     issues.  I am positive a final solution will follow.  I'm, however,

18     concerned about the information I personally received from some of our

19     services.  They tell me what the situation in Zagreb is, and we know what

20     happened in Vukovar, mass crime against the civilian population.  We will

21     interrogate perpetrators and bring them to court, national court.  I am

22     certain they will be published [as interpreted] accordingly for their

23     misdeeds.  It is no use to whine.  This is neither asked nor expected of

24     us.  Serbs never whined.  Serbs should fight and will fight to protect

25     their people.


Page 10443

 1             "Anchor:  You have already appealed to all able-bodied men to

 2     return to their homes and join their comrades who are already at the

 3     frontline.  Was the appeal successful?

 4             "Goran Hadzic:  The appeal was successful in every way.  A number

 5     of our combatants who fled now returned.  They are fighting in the first

 6     lines.  We also called volunteers from Serbia, irrespective of their

 7     party, Serbs to join our ranks and fight with Serb insignia for the

 8     imperilled Serb people.  They came.  I will take this opportunity to

 9     thank all of them who came to fight.  The group from Belgrade stands out.

10     They are always in the first combat lines.  They fight and get killed

11     just like us but are not hesitant to go all the way and win.

12             "Anchor:  What do you think, those of you who are in the field,

13     what is the actual condition that could lead to a truce, not the one

14     signed in cabinets but the actual truce in theatre of war?

15             "Goran Hadzic:  Well, there is a number of conditions.  The first

16     one is for Serbs to come to their senses - I refer to all Serbs within

17     the current borders of Yugoslavia - and realise that only Serb unity can

18     lead to final victory.  The second condition is that official Europe,

19     that is the world, the international community, realise that the Yugoslav

20     problem can only be realised by respecting the will of the people, in no

21     other way.  No foreign interference can help with this.  And the third

22     condition is to deal with this Fascist Ustasha nest in the Republic of

23     Croatia till the end firmly and decisively.  This means confronting them

24     with no mercy since they inflicted so much evil on the suffering Serb

25     people that there is no mercy for them, nor should there be.


Page 10444

 1             "Anchor:  Do you think that Serbs and Croats can live together?

 2     "Goran Hadzic:  Not the brotherhood and unity type of co-existence

 3     introduced 50 years ago, but knowing my people, I'm sure Serb will not

 4     harm anyone who is not harming them.  So all Croats who stay in our

 5     region, all Croats living here for years, like us, will be able to stay

 6     with us in the Serb region, have the same rights as everyone else, as

 7     Serb people, other nations and nationalities.  And the Croats who have

 8     blood on their hands and are wallowing in it, they will surely be held

 9     responsible for what they did.  We will have no mercy with them, and U

10     say this for the third time this evening.

11             "Anchor:  Thank you for being the guest of Dnevnikov Dodatak.  We

12     are moving on now."

13             MR. STRINGER:

14        Q.   Now, Mr. Hadzic, this testimony you've been giving us about

15     having as your only sources what you read in the newspaper in Belgrade,

16     you've just lied about that because now as you've said publicly and at

17     the time, you were getting information from what you referred to as "our

18     services."

19             Who are "our services" that you referred to in this televised

20     interview?

21        A.   Your Honours, I'm not a lawyer and I have to give a sincere

22     answer to this question.  If I were to say now that I had some service

23     that provided information to me, I think that it would be the duty of all

24     in this courtroom, the Prosecutors and the Judges, they would say:  Yes,

25     which services?  Why are you lying?  I wanted to sound important, to


Page 10445

 1     attach some importance to myself.  It's a silly lie.  When I say everyone

 2     knows -- well, of course, this is the first time you hear it, but I say

 3     everyone in Slavonia and Baranja knows, what kind of service?  I had no

 4     service.  I heard about the suffering of Serbs in Zagreb through the Serb

 5     media and some personal information from individuals, refugees who

 6     returned.  As for the suffering of Serbs in Vukovar, I heard about that

 7     from the Serbs who had fled from Vukovar so ... so these were these

 8     services of mine.  My services.  If I were to say now that I had some

 9     service, I would be lying.

10        Q.   Just like you were lying then, as you say, when you gave this

11     interview?

12        A.   Well, I'm under oath here.  And it doesn't really suit me to say

13     anything that is false or to lie.  But, at that time, I was a politician.

14     I was making statements.  You can call that a lie, but I just exaggerated

15     things.  I wanted to point out how important this information I had was.

16     That was my intention.  It wasn't my intention to lie.

17        Q.   Well, Mr. Hadzic, you lie when it suits you.  Just as you're

18     lying here today because you think it suits you to lie here today and to

19     minimise the level of your involvement and knowledge of what was going

20     on.  Isn't that true?

21        A.   Of course that's not true.  If I said some information that was

22     wrong or exaggerated things a bit, that doesn't mean that that was my

23     intention.  When somebody says that I destroyed mosques, I didn't say

24     that they were lying although it's obvious [Realtime transcript read in

25     error "often"] that that was not true.


Page 10446

 1        Q.   It also suited you in your role as prime minister of the SBWS

 2     during this period to stoke hatred and to encourage violence with the

 3     words that you're issuing here, no mercy, three times, as you said, and

 4     already you're setting the stage for the events that occurred once

 5     Vukovar fell and the prisoners were taken off to Ovcara, that is, the

 6     punishment for misdeeds.  Isn't that so?

 7             JUDGE DELVOIE:  Mr. Zivanovic.

 8             MR. ZIVANOVIC:  Your Honours, I notice in the last answer of

 9     Mr. Hadzic in -- it is page 30, line 15, the word "often."  As far as I

10     know he didn't mention this word at all.

11             JUDGE DELVOIE:  Should we ask Mr. Hadzic to repeat his answer,

12     Mr. Zivanovic?  Because I'm not quite sure I can make anything of it with

13     the word "often" or without the word "often."

14             MR. ZIVANOVIC:  Yes, he could repeat.  Maybe we can read out

15     whole -- whole answer between lines 12 and --

16             JUDGE DELVOIE:  Okay.  I'll read the answer.

17             Mr. Hadzic, you gave to Mr. Stringer's question:

18             "Of course, that is not true.  If" --

19             MR. ZIVANOVIC:  Yes, of course -- he didn't use the word "often."

20             JUDGE DELVOIE:  Just one moment.

21             This is on the record:  "Of course, that is not true.  If I" --

22             MR. ZIVANOVIC:  That's correct.

23             JUDGE DELVOIE:  "If I said some information that was wrong or

24     exaggerated things a bit, that doesn't mean that that was my intention.

25     When somebody says that I destroyed mosques, I didn't say that they were


Page 10447

 1     lying although it's often that that was not true."

 2             THE WITNESS: [Interpretation] No, "often" is there unnecessarily.

 3     I mean, I'm not impolite and I'm not saying that they lied.  I am just

 4     saying that it's not true.  So it's a mistake.  Very often this makes no

 5     sense.

 6             JUDGE DELVOIE:  So your answer is:  I do not -- I'm not saying

 7     that they were lying although it is not true.  That's your answer, right?

 8             THE WITNESS: [Interpretation] Yes, yes, correct.

 9             MR. STRINGER:  Thank you, Mr.  President.  Not to get too

10     technical but could I inquire whether the Registrar, whether these sorts

11     of interventions and clarifications are held against the Prosecution for

12     its time.

13                           [Trial Chamber and Registrar confer]

14             JUDGE DELVOIE:  Registrar says yes, Mr. Stringer.

15             MR. STRINGER:  It seems unfair.

16                           [Trial Chamber and Registrar confer]

17             JUDGE DELVOIE:  Sorry about that, Mr. Stringer.  A little

18     misunderstanding.  The answer is no, it is not on your time.

19             MR. STRINGER:  Thank you, Mr. President.

20        Q.   I want to just move quickly here in the next few minutes before

21     the break, Mr. Hadzic.  Continuing in the video, we can go back if you'd

22     like but you were asked about an appeal that you had made to all

23     able-bodied men to return their homes, join their comrades who were

24     already in the front.  You were asked if the appeal was successful and

25     you said the appeal was successful in every way.  So just to clarify, I


Page 10448

 1     think I'm going to suggest to you that you're referring there to the

 2     mobilisation order that you issued on the 23rd of August, 1991.  We

 3     looked at once before.  We could look at it again if you want.  It's

 4     P3217.

 5             But could we agree there that you're referring to the

 6     mobilisation order that you'd issued?

 7        A.   Well, that's possible, but you put a question to me and then my

 8     lawyer intervened and then I didn't answer that question.  And, in my

 9     view, the conclusion that you drew is very wrong and I am really bothered

10     by that, and I cannot leave from here without explaining that.

11             You said that I stoked hatred and that I called for revenge and

12     that is totally contrary to what I had intended.  I don't know whether

13     there's enough time for me to explain this before the break or should I

14     do it after the break because that's the question that you put and then

15     you moved on to a different question and then I didn't answer to --

16     answer this.

17             So if Their Honours remember --

18             MR. STRINGER:  Perhaps it's best left for after the break because

19     I'm sure there will be some follow-up on that, Mr. President.

20             JUDGE DELVOIE:  Okay.  So we take the first break.

21             Court adjourned.

22                          --- Recess taken at 10.29 a.m.

23                           --- On resuming at 11.01 a.m.

24                           [Trial Chamber and Registrar confer]

25             JUDGE DELVOIE:  Yes, Mr. Stringer.  Please proceed.


Page 10449

 1             MR. STRINGER:  Thank you, Mr. President.

 2        Q.   Mr. Hadzic, I want to stay on the issue of the volunteers.  We

 3     just saw the videotape where you were on the news broadcast in Belgrade.

 4     Actually, no.  Before the break, we were going to continue with this

 5     issue of your words that we just saw, the issue of what I called stoking

 6     up the public.  Here, in the video - three times as you said - saying

 7     that there would be no mercy to those involved in, with blood on their

 8     hands, as you said, I believe, those wallowing in the blood.

 9             So you wanted to tell the Chamber what you meant when you were

10     talking like that.  So please go ahead.

11        A.   Thank you.  I wanted to say that my intention was completely the

12     opposite of what the Prosecutor called stoking up.  I'll be very brief.

13             I had relatively very little political experience.  I had only

14     been active in my own village as the class president, et cetera.  But I

15     realised from primary school that whenever somebody has a contrary

16     opinion, in order to get through to that person and to prove that he is

17     not right, I have to apparently agree at first in order to achieve my aim

18     and that is to persuade that person.  So, in the beginning, I always made

19     a semblance of agreeing with that person but, at the end, I would say

20     that the criminals will be tried in the end and their guilt proven.  I

21     didn't -- that's why I said, at first, that the criminals will be dealt

22     with without trial.

23             I'm sorry if somebody misunderstood this here, but I'm telling

24     you what my intention was.

25        Q.   And just like before the recess, you indicated that you were


Page 10450

 1     sorry if people who heard you talking about ancestors of the Western

 2     Herzegovinians who had moved up into the SBWS region, you were sorry if

 3     people interpreted your words about them to be some sort of an

 4     incitement.  So this is just another example that, as you say, you didn't

 5     really mean what you were saying?

 6        A.   You abused my explanation, which was a general explanation.  This

 7     matter is completely different.  I said I was sorry for the people who

 8     hailed from Western Herzegovina and who were not Ustashas.  Although we

 9     know that from that region there were many people who were Ustashas.  We

10     know very well who Ustashas were, who Hitler was, who were Fascists.

11     It's a completely different example.  It has nothing to do with what I

12     meant to say.

13        Q.   Well, despite the fact that your only experience in politics,

14     apparently, was being the class president, you knew full well the effect

15     that words like this would have on the listening public.  Isn't that

16     true?

17             JUDGE DELVOIE:  Mr. Zivanovic.

18             MR. ZIVANOVIC:  Sorry, but I didn't see any reference in the last

19     document or the video presented here about people from -- from Western

20     Herzegovina.  He spoke about Croats but not particularly about the people

21     from Western Herzegovina.  If I could see the reference.

22             MR. STRINGER:  I'll provide a reference, Mr. President.  I don't

23     have it handy.  My recollection is that we spoke extensively with

24     Mr. Hadzic about a series of public statements he had made condemning

25     people, families, ancestors of those who had moved into the region from


Page 10451

 1     Western Herzegovina during the Ante Pavelic time in 1941.  That's what

 2     I'm referring to.

 3             JUDGE DELVOIE:  Mr. Zivanovic.

 4             MR. ZIVANOVIC:  As far as I know, it was some interview published

 5     in -- on 4th September 1991.  But in this particular document, he never

 6     put any difference between Croats and -- Croats from Western Herzegovina.

 7     In this video.  I -- I didn't --  I didn't --

 8              JUDGE DELVOIE:  Are you sure [Microphone not activated]?

 9             MR. ZIVANOVIC:  Yes.

10             JUDGE DELVOIE:  Are you sure?

11             MR. ZIVANOVIC:  In this particular video.

12             JUDGE DELVOIE:  Yes, without using the word "Herzegovina

13     Croats" --

14             MR. ZIVANOVIC:  Western -- Croats from Western Herzegovina in

15     this particular document.  I didn't see --

16             JUDGE DELVOIE:  [Overlapping speakers] -- didn't use that word in

17     this video.  But unless I'm wrong, he made a difference between those who

18     lived in his region for centuries and the other ones.

19             MR. ZIVANOVIC:  If it was the reference to the Western

20     Herzegovina specifically.  Or I don't know.

21             MR. STRINGER:  I can try to clarify, Mr. President, or I'll put

22     it to Mr. Hadzic.

23             The video that we just saw, P58, it doesn't refer to Herzegovina

24     Croats.  Here, he is referring to Croats with blood on their hands and

25     are wallowing in it and they will surely be held responsible for what


Page 10452

 1     they did.

 2     Now he says -- Mr. Hadzic has just testified that, if I may put it this

 3     way -- well, the Chamber has heard what he has to say.  I'm drawing a

 4     connection between these sorts of words made here and what the

 5     Prosecution views as similar incendiary-type language in the public

 6     statements made before, that we discussed about before, involving his

 7     condemnation and singling out of Herzegovina Croats.

 8             So this is another example of Hadzic, of Mr. Hadzic inciting and

 9     stoking violence against Croats, again, in his capacity as president of

10     the government of the SBWS.

11             Now, in this video, he is saying that:

12             "All Croats who stay in our region, all Croats living here for

13     years, will be able to stay with us in the Serb region."

14             Now, this is arguably, this is consistent with what he was saying

15     before, the statements about the Herzegovina Croats.  The Chamber may

16     recall the earlier testimony about the distinction between those who had

17     always lived in the region, the more peaceful ones from the flatlands,

18     versus the more aggressive ones from the mountainous regions, such as

19     Dalmacija and Western Herzegovina.  So there is a consistency here, but

20     it is all about stoking violence and inciting violence against Croats.

21     That's our point.

22             MR. ZIVANOVIC:  As far as I understood, Mr. Hadzic spoke about

23     the people who had blood on their hands and about Ustasha nests,

24     et cetera, et cetera.  He didn't mention any -- anyone from some

25     particular regions.

 


Page 10453

 1             JUDGE DELVOIE:  The discussion is on the record now.  Would you

 2     like to have your client further questions -- questioned about this,

 3     Mr. Zivanovic, or can we move on?

 4             MR. ZIVANOVIC:  We can move on, Your Honours.  Thank you.

 5             JUDGE DELVOIE:  Thank you.

 6             MR. STRINGER:  I believe, Mr. President, that we need to go into

 7     private session for the next exhibit, which is tab 1578 --

 8             JUDGE DELVOIE:  Private session.  Private session, please.

 9                           [Private session]

10   (redacted)

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Page 10454

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Page 10469

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20   (redacted)

21   (redacted)

22                           [Open session]

23             THE REGISTRAR:  We're in open session, Your Honours.

24             JUDGE DELVOIE:  Thank you.

25             MR. STRINGER:  Could we have tab 760, please.  65 ter 1939.21.

 


Page 10470

 1        Q.   Isn't that true, Mr. Hadzic, that in July of 1991, the very

 2     period we've been talking about here, you appointed Mr. Jovo Ostojic to

 3     be the commander of the Volunteer Recruitment Centre at Prigrevica?  This

 4     document comes from Mr. Petrovic's book.

 5        A.   I don't remember that.  And I think that no one consulted me

 6     about this, if he had been appointed at all.

 7        Q.   Well, this is the same time that you were making the appointments

 8     of the others, Mr. Malakovic, Mr. Kojic.  And, here, what we see is that

 9     you're also appointing Mr. Ostojic of the Volunteer Recruitment Centre in

10     Prigrevica.  You don't recall that at all?

11        A.   No.  I remember Janko Malakovic and Ilija Kojic.  I don't

12     remember that this existed at all.

13        Q.   And so it's your evidence that you absolutely deny having

14     appointed Mr. Ostojic to be the commander of this training centre?

15        A.   I think that this is the first time I hear of this.  I don't know

16     whether this happened -- I mean, this is the first time I hear of this.

17        Q.   Well, if you could just take a moment to think back, I'll ask you

18     one last time:  Did you appoint Mr. Ostojic to be the commander of this

19     Prigrevica training centre?

20        A.   I really do not remember that, and I don't remember that this

21     centre existed at all.

22        Q.   Could we take from that that you actually deny having made this

23     appointment, you reject this document?

24        A.   I think I did not do that, and I don't remember this at all, that

25     something functioned in that sense.  Had that happened, I would have


Page 10471

 1     remembered.

 2        Q.   Let's go to tab 421 then, which is P143.  This is from a

 3     publication called "Velika Srbija."

 4             "Velika Srbija" meaning great or Greater Serbia, is that -- is my

 5     understanding of that correct, Mr. Hadzic?

 6             JUDGE DELVOIE:  Mr. Zivanovic.

 7             MR. ZIVANOVIC:  Sorry, but Velika Srbija could mean -- could be

 8     translated either like great Serbia or Greater Serbia, not both.

 9             JUDGE DELVOIE:  Why?

10             MR. STRINGER:  Well, that's why I asked Mr. Hadzic --

11             JUDGE DELVOIE:  Why shouldn't we have waited for Mr. Hadzic's

12     response, Mr. Zivanovic?  I mean, if you object to Mr. Hadzic performing

13     translation, then we could have asked the interpreters.

14             MR. ZIVANOVIC:  Sorry, it is just an issue of translation.

15     Nothing else.

16             JUDGE DELVOIE:  Please continue, Mr. Stringer.

17             MR. STRINGER:

18        Q.   Well, just perhaps for -- to clarify it, I'll just read the words

19     and perhaps the interpreters could -- could give it to us back in

20     English.

21             Velika Srbija.

22             THE INTERPRETER:  It's either great Serb or Greater Serbia.

23             MR. STRINGER:

24        Q.   And in paragraph 1, Mr. Hadzic, of this publication, it's

25     referring -- this document refers to the things done by this Kragujevac


Page 10472

 1     Chetnik detachment.  And again we see:

 2             "It was sent on its first assignment to the command of the

 3     Serbian Chetnik movement on 19 July, 1991.  The detachment was to be

 4     stationed in the village of Prigrevica with other volunteers from Serbia

 5     and undergo supplementary training there."

 6             Do you see that?

 7        A.   I see that.

 8        Q.   So, in fact, there was a training centre in Prigrevica where

 9     volunteers, such as members of the Chetnik Movement, came and trained and

10     were staged before moving into Slavonia.  True?

11        A.   I don't have that information.  From the information I had at the

12     time, all volunteers who came in arrived through the barracks called

13     Bubanj Potok in Belgrade.  That's what I knew at the time.  I don't know

14     about this.  It's possible.

15             MR. STRINGER:  Could we please have tab 1591, 65 ter 6518.

16        Q.   We're going to go back in time just a little bit, Mr. Hadzic.

17             This is a poster for a peaceful resolution -- I should say, a

18     poster regarding -- to organise a rally for the peaceful resolution of

19     the crisis.

20             This is Jagodnjak on the 21st of April, and it's announcing

21     various persons who will speak.  This is the Jagodnjak rally that we've

22     seen the film of at various times in the trial, isn't it, and which

23     Mr. Paroski made the statements about?

24        A.   Yes, I remember that.

25        Q.   And here, Mr. Seselj, we know from the video that he did speak.


Page 10473

 1     We know that Milan Paroski did speak.  Can he saw that on the video-clip.

 2     You're listed as one of the speakers.  Did you speak at this event?

 3        A.   No, I wasn't even there.  I see this poster for the first time

 4     now and my name on it.  I wasn't invited, and, if I had been, I wouldn't

 5     have gone.

 6        Q.   And Jovo Ostojic is also indicated as one of the speakers here,

 7     as president of the Regional SDS Board for Backa.  Do you see that?

 8        A.   I see that, but I cannot give evidence about that.  I only know

 9     as much as the rest of you.  I don't know any more.  I wasn't present

10     there, and nobody told me anything, in particular, about it.

11        Q.   But you do know that he played a role in the SDS,

12     Serbian Democratic Party, at least as of this time.  You already told us

13     that subsequently he moved over to the Serbian Radical Party.  True?

14        A.   I see now that he was in the Serbian Democratic Party, but he did

15     not emphasise his party membership.  So, at that time, I didn't even know

16     it.  But the board for Baranja was a separate board in parallel with the

17     Vukovar board, so they organised their rallies autonomously without

18     consulting anyone from Vukovar.

19        Q.   Do you know when he switched and became a member of the

20     Serbian Radical Party?

21        A.   I don't know.  I have no clue.  I never discussed Jovo Ostojic

22     with anyone.  Never exchanged three words about Jovo Ostojic with anyone.

23     Didn't know anything about him.

24        Q.   Just looking at some of the names on this document, Mr. Hadzic,

25     based on what we've seen and discussed, can we agree that Mr. Seselj,


Page 10474

 1     Paroski, and Jovic were all personally involved in recruiting volunteers

 2     who would come to fight in Croatia?

 3        A.   You said Seselj, Paroski, and Jovic?  Those three names; right?

 4     From what I know, they did organise volunteers.  But that's information I

 5     received subsequently.

 6             MR. STRINGER:  Mr. President, we tender this, 65 ter 6518.

 7             JUDGE DELVOIE:  Admitted and marked.

 8             THE REGISTRAR:  Exhibit P3225, Your Honours.

 9             JUDGE DELVOIE:  Thank you.

10             MR. STRINGER:  And just to stay briefly for another minute or two

11     with Mr. Ostojic before the break, could we please have tab 1056, P3137.

12                           [Prosecution counsel confer]

13             MR. STRINGER:  And that would be 65 ter 4921.8 for the

14     interpreters.

15             THE INTERPRETER:  We have it.

16                           [Video-clip played]

17             THE INTERPRETER: "[Voiceover] ... battle-field in Krajina.  We

18     visited today another unit of volunteers that is protecting the borders

19     with Krajina, that during the last two years of war have been present at

20     every place where the Serbdom and the Orthodox faith have been

21     threatened.

22             "One of the reasons of our visit was a successful operation

23     carried out several days ago in which 16 Ustashas were liquidated.  On

24     this occasion, Serbian volunteers were visited by the commander of the

25     Main Staff of the Republic of Serbian Krajina, General Mile Novakovic,


Page 10475

 1     and Minister Milan Martic.  General Novakovic congratulated the soldiers

 2     on the successful operation and stressed that their unit can be a role

 3     model for all those who are defending Serbdom.

 4             "Novakovic:  Main Staff of the Serbian army especially

 5     appreciates Serbian volunteers who came to these western parts of the

 6     Serbian state to defend it, to try to defend and defend successfully

 7     these people and these territories of ours.  We appreciate you because we

 8     know that you did not come here to fight because of some personal image

 9     of yourself but because of some war glory of yours because of some

10     egocentric interests.  We know that you came to fight for freedom and the

11     honour of Serbian people."

12             THE INTERPRETER:  Interpreter's note:  We had no sound at all so

13     we don't know exactly where to stop.

14             MR. STRINGER:  Okay.  That's -- apologies for that.  That's good

15     for now and then we'll continue, and we can even go back and replay it if

16     it would assist.

17        Q.   Mr. Hadzic, just looking at the image in front of us, are you

18     able to recognise either of the two people on the left of the screen?

19        A.   First one was the General Mile Novakovic.  And the one with the

20     beard is Jovo Ostojic.

21        Q.   And just for the record, tell us who was General Mile Novakovic?

22     What was his background and what was his function at this time.

23        A.   He was an ex-colonel of the Yugoslav People's Army, hailing from

24     a village called Kirin in the region of Kordun, and he was the commander

25     of the Serbian Army of Krajina.


Page 10476

 1        Q.   You said he was an ex-colonel of the Yugoslav People's Army.  In

 2     fact, during the time that he was commander of the RSK army, he was still

 3     on the payroll of the JNA, wasn't he?

 4        A.   I think he was.  They talked about it, but I'm not sure.  And I

 5     tried to tell you more about him naming the village where he came from,

 6     et cetera, because that's how I understood your question.

 7        Q.   Thank you.

 8             MR. STRINGER:  Mr. President, we could --

 9             MR. ZIVANOVIC:  I think the answer of Mr. Hadzic is not correctly

10     transcribed.  If he could repeat it.

11             JUDGE DELVOIE:  Could you repeat your last answer, Mr. Hadzic.

12             THE WITNESS: [Interpretation] I understood when the Prosecutor

13     asked who he was and where he hailed from, I gave a broader answer,

14     saying where he was born and that he was an ex-colonel of the

15     Yugoslav People's Army.  I wasn't talking about the position he was

16     occupying when he was photographed here.

17             MR. ZIVANOVIC:  Sorry, for the clarification, it would be useful

18     to -- to read both the question and his answer between lines 19 and 24.

19     It could be done by the Prosecution or by me or anybody else.

20             MR. STRINGER:  I can try to clarify it, Mr. President, although

21     it's time for the break.

22             MR. ZIVANOVIC:  It is actually the second sentence in the

23     response of Mr. Hadzic.

24             JUDGE DELVOIE:  What do you take as the second -- sorry.  The

25     second sentence is which one?  They talked about it.


Page 10477

 1             MR. ZIVANOVIC:  [Microphone not activated] They talked about it.

 2             JUDGE DELVOIE:  But I'm not sure.  And did he say something else?

 3             MR. ZIVANOVIC:  Yes, he said they didn't talk about it.

 4             JUDGE DELVOIE:  Okay, Mr. Hadzic.  Did they talk about it or

 5     didn't they talk about it?  About -- about the fact --

 6             THE WITNESS: [Interpretation] I said we didn't discuss it.  I

 7     didn't ask him who was paying his salary.  We didn't ask any personal

 8     questions.

 9             JUDGE DELVOIE:  Okay.

10             Time for the break.  Court adjourned.

11                          --- Recess taken at 12.17 p.m.

12                           --- On resuming at 12.48 p.m.

13             JUDGE DELVOIE:  Mr. Hadzic, we were told that you have a question

14     for us.

15             THE WITNESS: [Interpretation] A short technical matter.  When

16     will I have the right to see my lawyers?  At the end, when the Prosecutor

17     finishes?  Or at the end of the redirect?  I don't know at which stage we

18     are.  I don't know who the first witness will be.  I have no information

19     whatsoever these days.

20             JUDGE DELVOIE:  Mr. Hadzic, Mr. Zivanovic, I -- I thought that

21     the directions we gave were clear enough to let you know that you can

22     have -- you, Mr. Hadzic, can have contact with Defence counsel for the

23     preparation of other witnesses.  As from now, there is no ban on that

24     kind of contact.

25              So if it is not -- it is not about the substance of your


Page 10478

 1     testimony -- of your own testimony, there's no problem at all.

 2             Is this helpful?

 3             THE WITNESS: [Interpretation] All right.  But when will I have no

 4     normal contact with my Defence counsel?  Do I have to wait until the end

 5     of the re-direct or when the Prosecutor finishes?  Because I'm not a

 6     lawyer, all these things are not so clear to me.

 7             JUDGE DELVOIE:  That is when you step down from the

 8     witness-stand, Mr. Hadzic, and that would be after re-direct.

 9             THE WITNESS: [Interpretation] Thank you, Your Honours.

10             JUDGE DELVOIE:  You're welcome.

11             Mr. Stringer.

12             MR. STRINGER:  Thank you, Mr. President.

13        Q.   Mr. Hadzic, just before the break, we were looking at the video

14     and talking about the video that showed General Novakovic and

15     Mr. Ostojic, and let's just play another part of that and then we can

16     move on.

17             MR. STRINGER:  I believe the interpreters should still have it

18     handy.

19             THE INTERPRETER:  Which one was it could you remind us.

20             MR. STRINGER:  That was P3137 --

21             THE INTERPRETER:  Yes.

22             MR. STRINGER:  Okay.

23                           [Video-clip played]

24             THE INTERPRETER: [Voiceover] "The Serbian volunteers who arrived

25     in these western parts of the Serbian land to defend these people and our


Page 10479

 1     territories.  We appreciate you because we know that you did not come

 2     here to fight because of some personal image of yours, because of some

 3     war glory, because of some egotistic interests of yours.  We know that

 4     you came here to fight for the freedom and honour of the Serbian people.

 5             "Reporter:  Vojvoda duke Jovo Ostojic, who is at the head of this

 6     elite unit, appealed to all the Serbs who have not yet done so to join in

 7     the ranks of the defence, because Serbdom is defended in neither Belgrade

 8     nor Knin.  It is defended everywhere where Serbs are attacked.  Amongst

 9     Serbian volunteers there are members of all political parties but none of

10     them are at this moment interested in politics.  They're all fighting

11     under the single command of the Main Staff of the Army of the Republic of

12     Serbian Krajina.

13             "Ostojic:  The motto of our soldiers is patriotism and freedom of

14     the Serbian people and there is nothing else.  We wish to defend Serbian

15     lands.  We want to defend Serbian children and Serbian mothers and to

16     deal with the Ustasha devils in a soldierly and heroic manner.  And I

17     would send them the following message:  Let them not touch young

18     children.  Let them be man enough and let them stand in the battle-field.

19     Let them choose their own weapon.  We are ready.  It is very difficult

20     for us, for me.  Here there are Croatian women and children and not a

21     hair on their heads must be touched while they thrust knives into our

22     children and cut their throats."

23             MR. STRINGER:

24        Q.   Mr. Hadzic, just to round this off, you were aware, since you

25     were president of the republic, that Mr. Ostojic led a group of Chetniks,


Page 10480

 1     volunteers out and fought as part of the RSK armed forces then.  You are

 2     aware of that; correct?

 3        A.   There were many volunteers.  I don't specifically remember that.

 4     Nobody reported that to me, in particular.  I know that when Maslenica

 5     was attacked, hundreds and thousands of men came to defend that part of

 6     Krajina.

 7        Q.   I take it then that if I were to suggest to you that, as it's

 8     indicated here, he's leading a group of volunteers fighting in RSK, you

 9     would not dispute that?

10        A.   No, no.  I'm not disputing that.  That's true.

11             MR. STRINGER:  Could we please have tab 685, P2685.

12        Q.   And this has already been referred to by you, I belive, already,

13     Mr. Hadzic, and it's already in evidence this document, which is to tie

14     this off.  This is 13th of May, 1993, central homeland administration of

15     the Serbian Chetnik movement, and if you go to the bottom of the document

16     you see that it appears over the name of Mr. Vojislav Seselj.  These are

17     appointments, and if we go to page 5, item 13, beginning of the bottom of

18     this page and then we'll continue to the next page.  According to this,

19     then -- and this is Dr. Seselj appointing Mr. Jovo Ostojic to be a

20     Serbian Chetnik Vojvoda.  That is a duke; correct?  You knew about this

21     at some point.

22        A.   I'm giving you second- or third-hand evidence.  I just heard

23     about it.  I believe it's true.

24        Q.   And then it says here.  And it may be necessary to move to the

25     next page that he -- actually, may be necessary to move to the next page


Page 10481

 1     of yours in B/C/S.  I think we're okay in English.  But it says that he

 2     organised and prepared Chetnik volunteer units across Backa and then

 3     personally led them in the war-effected territories or Slavonia, Baranja,

 4     and Western Srem.  You do know that that was, in fact, what was taking

 5     place at the time during the conflict in 1991, don't you?  He was among

 6     those of the Chetnik movement fighting in Slavonia, Baranja, and Western

 7     Srem?

 8        A.   I knew that he was in Palaca village, I think, close to Osijek,

 9     in co-ordination with the JNA, that is to say, as part of the Yugoslav

10     People's Army, and he had with him a number of his friends from

11     Prigrevica.

12        Q.   So you knew that he came from Prigrevica with others?

13        A.   I heard about -- from Milan Milanovic, Mrgud.

14        Q.   Do you know what units of the JNA Mr. Ostojic fought with in this

15     Osijek region?

16        A.   It's territory of the former Osijek municipality.  He was

17     defending the Serbian village of Palaca.  It was some units which was

18     part of the Osijek brigade, I believe, but it was totally under the

19     command of the JNA, integrated into the JNA.

20        Q.   So this would eventually be JNA forces that were under the

21     command of General Biorcevic?

22        A.   I don't know whether it was at the beginning or at the end, but

23     it was in that sector where Commander Biorcevic was.  You're right.

24        Q.   So it would have been Bratic or Biorcevic, depending on the

25     time-frame?


Page 10482

 1        A.   Yes, with the proviso that Biorcevic was Chief of Staff to Bratic

 2     so the two were there at the same time.  But I didn't know it at the

 3     time.  I learned it later.

 4        Q.   Right.  And then we talked about this earlier in your cross.  I

 5     can't recall the date offhand, but then I believe it was in October

 6     General Bratic was killed, and at that point General Biorcevic replaced

 7     him.  True?

 8        A.   Yes, that's true.

 9        Q.   I'd like now to go back to the video P0058, which we looked at at

10     the beginning of this section just to follow up on one last thing before

11     we move on.  And we're actually going to -- if we make take a moment to

12     try to skip forward because I don't think we need to replay the whole

13     thing again.

14             THE INTERPRETER:  Interpreter's note:  Could we please have the

15     65 ter number.  Thank you.

16             MR. STRINGER:  4873.2.  Let's just start it from the beginning

17     and let it run and then we can stop.

18                           [Video-clip played]

19             THE INTERPRETER: [Voiceover] "Well, the situation is much clearer

20     from a military point of view.  We have a big part of free liberated

21     territory in our area, that is, the whole of Baranja, Western Srem from

22     Vinkovci in the direction of Sid, and bigger part of this Osijek field,

23     that is, the territory between Osijek and Vukovar.  Vukovar is

24     currently blocked.  We expect denouement of the situation in Vukovar any

25     day.  We are capable of dealing with this quickly but we are thinking of


Page 10483

 1     human lives and taking care that this would be done slowly and securely

 2     with as little casualties as possible.  That is, we do not want any

 3     casualties.

 4             "Anchor:  Do you have information on events in Vukovar?  Do you

 5     have information on Serb people in Zagreb?  All communication lines are

 6     down.  There is no phone connection.  People cannot talk to their

 7     families.

 8             "Goran Hadzic:  As I said, I am not concerned with military

 9     issues.  I am positive a final solution will follow.  I am, however,

10     concerned about the information I personally received from some of our

11     services.  They tell me what the situation in Zagreb is, and we know what

12     happened in Vukovar, mass crime against the civilian population.  We will

13     interrogate perpetrators and bring them to court, national court.  I am

14     certain they will be punished accordingly for their misdeeds.  It is no

15     use whining.  This is neither asked nor expected of us.  Serbs never

16     whined.  Serbs should fight and we will fight to protect their people.

17             "Anchor:  You have already appealed to all able-bodied men to

18     return to their homes and join their comrades who are already at the

19     front line.  Was the appeal successful?

20             "Goran Hadzic:  The appeal was successful in every way.  A number

21     of our combatants who fled now returned.  They are now fighting in first

22     lines.  We also called volunteers from Serbia, irrespective of their

23     party, Serbs to join our ranks and fight with Serb insignia for the

24     imperiled Serb people.  They came.  I will take this opportunity to thank

25     all of them who came to fight.  The group from Belgrade stands out.  They


Page 10484

 1     are always in the first combat lines.  They fight and get killed, just

 2     like us, but we are not hesitant to go all the way and win.

 3             "Anchor:  What do you think?  Those of you who are in the field?

 4     What is the actual condition ..."

 5             MR. STRINGER:  Thank you.

 6        Q.   Mr. Hadzic, the last follow-up questions on this video, then,

 7     are, first of all, you say:  "We also call volunteers from Serbia."

 8             When you say "we," you're referring to yourself and who else?

 9        A.   I mean the Serbs from Slavonia, Baranja, and Western Srem, the

10     government, and myself, all of us who were born there.

11        Q.   And that would include the efforts made by you and Mr. Kojic

12     on -- in this regard.  I asked you questions about that earlier.

13        A.   Well, I've already given you an answer.  I don't know if you

14     understood what I said.  I said that I never dealt with volunteers or the

15     organisation of the transfer of volunteers, and I said I may have just

16     given political statements about that and nothing else.  So that should

17     be in the record.

18        Q.   When you say and refer here to the group from Belgrade that

19     stands out, are you referring to the volunteers such as those coming from

20     the -- the Radical Party, the Chetnik Movement, among others?

21        A.   Well, I'll tell you specifically what this is about.  Passing

22     from Dalj towards Erdut, I saw a very painful thing.  When a group of

23     regular reservists from Kragujevac --

24        Q.   I apologise to cut across you here, but I'm just asking you

25     simply tell us what groups did you have in mind when you referred to


Page 10485

 1     those from Belgrade.  What you say:  "The group from Belgrade stands

 2     out."

 3             Who you are referring to?

 4        A.   The group that had come from the Bubanj Potok barracks in

 5     Belgrade that took the place of those from Kragujevac who had cast away

 6     their weapons and who were lying there by the road.  That's what I was

 7     trying to tell you about.  And they had come as their replacement in

 8     order to fight.  And these men from Kragujevac were members of the party

 9     of Vuk Draskovic, the SPO, the Serbian Renewal Movement.

10        Q.   Serbian Renewal, Serbian Chetnik, these are also groups that were

11     coming across based on the work being done by General Pekic from what

12     we've seen.  Isn't that true?

13        A.   Well, I think this specifically what we're talking about is not

14     correct because it was first these regular reservists from Kragujevac who

15     had been mobilised in a regular way, and they were mostly supporters of

16     Vuk Draskovic, and they had defeatist attitudes toward the JNA and so on.

17     Whereas these people who came from Bubanj Potok came from the JNA.  I

18     don't know who had mobilised them, but I just know that the JNA gave them

19     uniforms and weapons.

20        Q.   We had looked earlier at P2685, Mr. Hadzic.  We can go back and

21     take a look but maybe we don't need to.  This was the document of

22     Dr. Seselj where he appointed Ostojic to be the Serbian duke.  We just

23     looked at this a few minutes ago.

24             The question is:  In item 10 of this, is where he also points a

25     person named Milan Lancuzanin, also known as Kameni, to be a Serbian


Page 10486

 1     Chetnik Vojvoda.  We can take a look, but would you accept if I suggested

 2     to you that Dr. Seselj also appointed Mile Lancuzanin as a Serbian duke?

 3        A.   Yes, I accept that.

 4        Q.   And he was the leader of a group of Chetnik volunteers who fought

 5     in the Petrova Gora area of Vukovar during the conflict.  Is that also

 6     true?

 7        A.   He is from Vukovar, but I think that he fought in the area of

 8     Leva Supoderica.  And that is what is written here.  That's a bit further

 9     away from Petrova Gora but it's similar.

10        Q.   In any event, the name of the unit that he led was called

11     Leva Supoderica?

12        A.   Yes.

13        Q.   And I read your testimony in Belgrade, back in 2003, when you

14     testified in the trial of Mr. Miroljub Vujovic, and at that time you

15     indicated that you knew Mile Lancuzanin but you knew his father better

16     because, as you said, they were from Vukovar; is that correct?

17        A.   Yes.  But I did not testify in Belgrade.  I gave a statement to

18     the investigating judge in Novi Sad.

19        Q.   You're correct on that.  It's Novi Sad proceedings against

20     Miroljub Vujovic.  That would be the 30th of September, 2003.  Does that

21     sound correct?

22        A.   I don't know the exact date, but I think it was 2003, yes.

23        Q.   And just to round this off, you've already said it but just to

24     make sure it's clear.  When you've talked about the volunteers that you

25     were aware of, it's my understanding, Mr. Hadzic, that in your view all


Page 10487

 1     the volunteers were under a unified chain of command within the JNA

 2     structure.  Is that a correct way of putting it?

 3        A.   You put that well.  And that's the only way it could have been.

 4     It couldn't have been any different.

 5        Q.   And that would also include the Leva Supoderica under the command

 6     of Mile Lancuzanin?

 7        A.   At the time when these things happened in 1991, I didn't know

 8     anything about Lancuzanin or that unit.  However, I found out later that

 9     this was under the command of the JNA as part of the Guards Brigade from

10     Belgrade.

11        Q.   Mr. Hadzic, I want to come back to a document that we've talked

12     about earlier.  This is 1D03600, which is tab 97.  This is the press

13     article that we tried to talk about, and I want to come back to it.

14             Do you remember this one?

15        A.   Yes, yes, I remember, we talked about it today and we tried

16     yesterday but we didn't have the right translation.  Yes, yes, I

17     remember.

18        Q.   And in connection with this, we also spoke about an article,

19     D118, which is from three days earlier, 13 July 1991, and we've actually

20     made a blow-up of it which might be more legible or readable for you.

21             MR. STRINGER:  And with the Chamber's permission, perhaps we

22     could give it to the witness.  Thank you.

23             THE WITNESS:  Thank you.

24             MR. STRINGER:

25        Q.   This was the article that you referred to during your direct


Page 10488

 1     examination that came in.  Remember this?

 2        A.   [Interpretation] Yes, yes, I remember, yes.  But I did not see it

 3     so I could not read it.  Could you now tell me which part I should look

 4     at?

 5        Q.   Well, before we look at specifics, let's just sort of set the

 6     context again because you had talked about this on direct.  This is in

 7     mid-July 1991 and, as I understand it, journalists, both foreign and

 8     domestic, had made it into Borovo Selo and were writing some articles and

 9     talking to people who were present, including yourself, and including

10     Vitomir Devetak; is that correct?

11        A.   Well, I don't know.  I did not see that when Devetak talked to

12     them.  I was not next to him when he was giving that statement.  I see

13     here that that is what he said.

14        Q.   Right.  I believe in your direct testimony you looked at this

15     article and -- and you -- well, looking at it now, starting with the last

16     part where it says "no reconciliation."  This is page 2 of the English.

17     It refers to a press conference that you gave.  You said:

18             "There would be no reconciliation with the government in Zagreb.

19     We're in favour of a peaceful and democratic way out of the crisis but

20     two sides are necessary for dialogue."

21             See that?

22        A.   Yes.  As opposed to the interpreter, I can see it and read it.

23        Q.   And then that's followed by some remarks given by Mr. Kojic who

24     also made a statement here; correct?

25        A.   Yes, yes, I see that.


Page 10489

 1        Q.   So if the earlier part of the -- the -- the article refers to

 2     statements by Mr. Devetak, are you challenging or disputing that he was

 3     also interviewed by the journalists?

 4        A.   Well, it's not that I have an opinion on that.  Anybody can say

 5     whatever.  I cannot confirm it or deny it.  Can you give your opinion

 6     too, just as I can.  I don't know anything about this.

 7        Q.   So the only thing about this article that you accept or adopt is

 8     the statement, the quote, that's attributed to you?  Everything else you

 9     cannot affirm or deny?

10        A.   Well, I'm not even sure that there was a press conference.  Maybe

11     I just gave a brief statement.  Had it been a press conference, it

12     probably would have involved a longer statement on my part.  But that we

13     were in favour of peace and a peaceful way out of the crisis, I agree

14     with that.  That was my position.

15        Q.   Going back to now the other document, the other article, which is

16     1D3600.  You see that, Mr. Hadzic?

17        A.   The one on the screen?  Yes, if that's what you mean.  Because I

18     cannot tell by its number.

19        Q.   All right.  The one on the screen -- and if we could scroll to

20     the right-hand side.  There.

21             What we see is a photograph.  Are you able to describe -- can we

22     agree that's you and another person?

23        A.   We can agree.

24        Q.   This says it's Milan Babic in Borovo Selo.  Was Milan Babic with

25     you in Borovo Selo during this period, July 1991?  I'm sorry, it doesn't


Page 10490

 1     say.  It refers to Babic.  I stand corrected.

 2             The question is:  Who is the person standing next to you, if you

 3     know?

 4        A.   It looks like Ilija Kojic to me, but the picture seems to be

 5     blurred.

 6        Q.   And do you recall an occasion of speaking to the press in Borovo,

 7     as indicated here, in July of 1991?

 8        A.   Well, in Borovo Selo, I talked to at least 30 journalists at

 9     different points in time.  This I cannot remember.  I don't think I

10     talked to this journalist from the Croatian paper "Danas."  I would have

11     remembered talking to a Croatian journalist.  There were Serbian

12     journalists, and there were also foreign journalists.  I even remember

13     this journalist from Japan that I talked to.

14        Q.   What's interesting to me, Mr. Hadzic, is this.  The caption of

15     the video -- of the photo, after referring to you as the Slavonian Babic,

16     which I don't know whether you would take kindly to or not, it says

17     that -- it's saying "Goran Hadzic announcing the impending uprising of

18     all Slavonian Serbs in Borovo Selo."

19             Do you see that?

20        A.   I see that.

21        Q.   And at that time, in July of 1991, in Borovo, isn't that what you

22     did?  Didn't you make a statement, at least one statement, in which you

23     referred to an impending uprising of the Serb people?

24        A.   Not in this negative context as somebody wanted to portray it in

25     the newspapers that were on the opposite side then, opposite to me, my


Page 10491

 1     policy and my people, after all, and that carried a great deal of false

 2     information about our side.  At that time, there was an information war

 3     going on.

 4        Q.   Well, in what context, then, if you could just tell the Chamber,

 5     what context, then, would you have referred to an impending uprising?

 6     What would be your reason for making a statement about that?

 7        A.   Well, when speaking of the month of July, I can remember now the

 8     problems that we had.  On the 7th of July, Tenja was attacked, and a

 9     great many casualties were avoided at one point.  The Croats almost

10     massacred an entire village.  They barely defended themselves.  Mirkovci

11     was attacked as well, and they were constantly under attack.

12             In a way, I was asking the federal state for help.  The

13     Presidency of the SFRY.  I asked the JNA for protection.  And I also

14     asked the people who were supposed to protect us under oath.  I said that

15     we sought their help because otherwise the Serb people could not defend

16     themselves on their own.  I mean the Serb people in Slavonia, Baranja,

17     and Western Srem, whereas that has nothing to do with this comment in the

18     newspaper.

19        Q.   Now if we go back to D118.

20             MR. STRINGER:  If we could please put that up.

21        Q.   And, Mr. Hadzic, this is the hard copy that you've got.

22             I want to go back to the passages that are attributed to you and

23     then to Ilija Kojic.  So this would be page 2 of the English.

24             The statement attributed here to Mr. Kojic, and this is -- well,

25     before we get to that, this is "Politika."  This is a publication that


Page 10492

 1     you've got more confidence in, I take it; correct?

 2        A.   Well, from this angle now, 20 years later, not much more because

 3     the Serb and Croatian side did not have a fair or correct attitude, more

 4     or less, towards the things that were happening.

 5        Q.   This is a Serbian journalist, Mr. Rade Rankovic, writing this.

 6        A.   I don't know him.  Never heard of him.

 7        Q.   Does it seem to you that he's a Serb, Serbian, or Serb

 8     journalist?  Based on his name.

 9        A.   Well, based on his name, I'm almost sure he is.

10        Q.   What is interesting, Mr. Hadzic, is that here Mr. Kojic, in this

11     article, in statements attributed to him in which he is referring to the

12     same thing.  He says that:  "If the terror against the Serbian population

13     in the Osijek area and elsewhere does not stop, a general uprising of the

14     people may be expected."

15             Now in 3600, the other document, we've got the photograph of the

16     two of you standing there being interviewed.  My question is which one of

17     you made that statement about a general uprising?

18        A.   This is a very interesting thing that you've said just now, as we

19     were being photographed as we are making a statement.  They took a

20     picture of us as we were strolling after that.  How do you know that they

21     were taking a picture of us as we were being interviewed?  Give me an

22     answer to that and then I'll answer.

23        Q.   It's not a coincidence, Mr. Hadzic, that in one of the articles,

24     the one under the -- the -- the caption under the photograph with you and

25     Mr. Kojic there's reference to an uprising.  And then we see the same


Page 10493

 1     reference, although attributed to Mr. Kojic, in your article, the one you

 2     tendered into evidence, D116.

 3             I'm asking you:  Who made the statement about an uprising, or did

 4     both of you?

 5        A.   I cannot speak in the name of Ilija Kojic.  I do not remember

 6     that I said that.  And as for this article that we had tendered into

 7     evidence, as you say, I don't see that the journalist quoted me.  It is

 8     written as a caption underneath a photograph, but I did not say that.

 9     Now whether Ilija Kojic said that, maybe did he, and maybe he didn't.  I

10     don't know.

11             MR. STRINGER:  Mr. President, we tender this article, D3600, into

12     evidence.  It's our position that there's sufficient corroboration as

13     between the two articles, overlap in respect of this issue, and we tender

14     it for purposes of the text that's attributed to Mr. Hadzic under the

15     photograph.

16             JUDGE DELVOIE:  Admitted and marked.

17             THE REGISTRAR:  As Exhibit P3226, Your Honours.

18             MR. STRINGER:

19        Q.   Mr. Hadzic, on the 8th of July, 2004 - and this was in private

20     session so I'm going to be careful but it may be necessary to go into

21     private session, Mr. President, we'll see - you spoke about a trip that

22     you took to Novi Sad.

23             MR. STRINGER:  Mr. President, I do believe we need to go into

24     private session.

25             JUDGE DELVOIE:  Private session, please.

 


Page 10494

 1                           [Private session]

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)


Page 10495

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9                           [Open session]

10             THE REGISTRAR:  We're in open session, Your Honours.

11             JUDGE DELVOIE:  Thank you.

12             MR. STRINGER:  This is page 9559.

13        Q.   You were asked:

14             "Q.  Was there any discussion on that occasion about weaponry and

15     the various places where it was stored in SBWS?"

16             And your answer was:

17             "We asked if he could be of assistance to us, if he could direct

18     us to somebody who could supply us with weapons, because we had a lot of

19     personnel and very few weapons."

20             Do you recall that?

21        A.   [No interpretation].

22        Q.   Now this is in late July of 1991, and what I'd like to point out

23     to you and ask your reaction is to suggest that as of this point in time,

24     you're meeting with Mandaric regarding obtaining weapons, regarding your

25     meeting with retired General Pekic regarding weapons, we know in the fall

 


Page 10496

 1     of 1991 you're in the Ministry of Defence, General Simovic with Arkan,

 2     asking for weapons.  That's the evidence we got from General Djordjevic.

 3             So if seems to me, Mr. Hadzic, that you devoted a significant

 4     amount of time in your capacity as president of the SBWS, or its

 5     government, or here in July as a member of the Serbian National Council

 6     to help to obtain weapons and to arm Serbs in Eastern Slavonia.  Is that

 7     true?

 8        A.   Unfortunately, that's not true.  I would have liked for my

 9     efforts to have been more successful but, unfortunately, I didn't achieve

10     anything except this little thing with Pekic.

11             MR. STRINGER:  Could we please have tab 186, P2987.  This is a

12     report coming from Novi Sad Television, and in the English, we're looking

13     at the right-hand column where it says:  Councils expect decisive attacks

14     by Serbs, 24 July 1991.

15        Q.   In the fifth paragraph here, Mr. Hadzic, it says:

16             "Because of the aggravated political situation, the Executive

17     Committee of the National Council for SBWS met in Borovo Selo last night.

18     In a statement for Novi Sad Radio and Television, Hadzic, president of

19     the government, stressed that armed Serbs are still on defensive but they

20     will soon launch a decisive attack.  Their aim is to liberate themselves

21     from the revived Ustasha authorities ..."

22             And then it continues down and the last sentence reads:

23             "This will be much sooner and will last for a much shorter time

24     than even the greatest optimists expect, Hadzic thinks."

25             Now, do you recall the meeting in Borovo Selo that's referred to


Page 10497

 1     here?  Meeting of the Serbian National Council.

 2        A.   I remember that we met at one point in Borovo Selo, but I can't

 3     remember the subject of that meeting.  I don't think the journalist

 4     quoted it very well.  I think he added some of his own opinions.

 5        Q.   But you do agree, or do you dispute the statement that's

 6     attributed here where you indicated that the Serbs would soon launch a

 7     decisive attack?

 8        A.   I gave at least ten such statements within a month or two, within

 9     ten days even.  And I meant the events about Vukovar, the attacks on the

10     barracks, and the provocations and the shelling of Borovo Selo, and this

11     was more of a threat for them to stop it.

12        Q.   Well, in fact, what is happening here we know -- this is

13     because - I'm going to suggest to you - this is consistent with the

14     statement that's attributed to you in the newspaper article we just saw,

15     which was 1D3600.

16             You're making these statements because you, in fact, know that

17     the Serb uprising, or the liberation, the attack, is forthcoming, and

18     that's the attack in Dalj that occurred on the 1st of August, and, in

19     fact, your statements on this point are linked directly to the coming

20     assault on Dalj that occurred on that day.

21        A.   That is not true.  First of all, I didn't know about the

22     forthcoming attack on Dalj.  And regardless of my IQ and my common sense,

23     I'm not so stupid that just before the attack on Dalj, I would announce

24     it to the journalists.  I'm not that crazy.

25        Q.   And, in fact, this is also linked then to your need to travel to


Page 10498

 1     Novi Sad and to meet with Mandaric during this very same time-period.

 2     They're all linked together, aren't they?

 3        A.   That's not true, and it's not true for several reasons.  I said

 4     that I went to see Mandaric for the formal reason of discussing

 5     something, including weapons, but the main reason was to leave from

 6     Borovo Selo with somebody in a high position because people had already

 7     started accusing of me doing nothing, so I wanted to be seen as doing

 8     something.  And I also needed a driver so I took somebody with me.

 9     Mandaric's office was not the place where you could discuss anything

10     serious.  Mandaric did not belong to the Command of the JNA, nor did I

11     have any contact with any operative commanders in the JNA, people who

12     decided anything.

13        Q.   I'd like to move to now tab 1047.  This is the video footage of

14     the visit of Mr. Kostic we looked at yesterday, although we're going to

15     play a bit more of it.  This is P241.  65 ter 4895.1.

16             THE INTERPRETER:  We've got it.

17                           [Video-clip played]

18             "THE INTERPRETER: [Voiceover] Vice-President of the Presidency,

19     Branko Kostic, visited Borovo Selo today.  Talking to the citizens,

20     Kostic stated, among other things, that those defending their homes

21     cannot be called bandits or terrorists.  He criticised the federal

22     government for what he called insufficient support for the refugees and

23     he positively evaluated the role of the JNA.  'You people in Borovo Selo

24     can count on the support of the Presidency and other federal organs.  The

25     fact that they call you Chetniks and terrorists is absolutely without


Page 10499

 1     foundation,' Kostic emphasised.  'You are only self-organised and armed

 2     people.'  In Branko Kostic's view, Croatian and Slovenian secessionists

 3     policies can either be tolerated nor accepted.  Should such unilateral

 4     acts be accepted, at least 70 states could be created in Europe.

 5             "Reporter:  As you can see, ladies and gentlemen, several hundred

 6     citizens welcomed Branko Kostic, vice-president, of the Yugoslav

 7     Presidency and Brana Crncevic in Borovo Selo.

 8             "Branko Kostic:  I visited Vucji Dol yesterday, one of the

 9     shrines of our history.  I regard you, here, as offspring of those heros

10     who were always ready throughout our history to defend both their homes

11     and their freedom.  Keep it up and be brave.

12             "[Applause]."

13             "Some of my colleagues, and you know who I mean, call you

14     outlaws, Chetniks, terrorists.  I always reply to that that the outlaws

15     are the ones who violated the Yugoslav constitution and passed unilateral

16     decrees, not you who are fighting for that constitution and that

17     Yugoslavia.

18    "Brana Crncevic: Mr. Kostic said what's important. The most important part

19    is what he said at the end: rest assured that you are not alone, and if

20    you are bandits, then there are other bandits who will come to defend you.

21             "Reporter:  After the warm welcome in Borovo Selo, vice-president

22     of the Yugoslav Presidency, Branko Kostic, met the leadership of the

23     Serbian Autonomous Region of Slavonia, Baranja, and Western Srem,

24     Goran Hadzic, president of the National Council, briefed him on the

25     current situation in the area.


Page 10500

 1             "Goran Hadzic:  These people are neither Chetniks, nor

 2     terrorists, nor are they bandits.  This is Serb folks, and I can now say

 3     a part of the honourable Croatian population is with us.  They are with

 4     us there at the barricades.  They do not recognise Ustashas' authorities

 5     and they do not wish to experience genocide as we suffered it 50 years

 6     ago.

 7             "Reporter:  Among other things, Branko Kostic stated that we are

 8     faced with a frenzied ideology in Croatia conceived as far back as 50

 9     years ago.

10             "Branko Kostic:  These policies are still fresh in our memory of

11     both Europe and the world.  I was convinced -- I am convinced that today,

12     too, both Europe and the world will finally grasp the implications of

13     that policy, as well as the fatal consequences that policy must bring

14     about, not only for the Serb people in the area of Croatia that are most

15     directly at risk but also the consequences such policies might bring

16     about elsewhere in Europe.  Our federal organs, particularly the federal

17     Executive Council, have by now failed dismally as we are dealing here

18     with an area at risk where it is the Serb people who are suffering.

19     However, both in this and in all of the other cases, the federal

20     Executive Council must be fully and financially responsible for it,

21     regardless of the ethnic affiliation of the population overtaken by

22     misfortune.  We shall do everything to have that Yugoslav People's Army

23     of ours, which is strong and powerful, which has sufficient manpower and

24     weapons, offer assistance and support to all people who become endangered

25     or are endangered already.  Regardless of their whereabouts.  Today, it


Page 10501

 1     is the Serb people in the area of Croatia that are at risk.  If the

 2     events unfold the way none of us would like them to, we cannot rule out

 3     the possibility of other parts of other nations to become endangered in

 4     certain other areas.  Our army must be that power and that national army

 5     in the proper sense of the word that will protect each and every of our

 6     citizens at risk, regardless of their nationality or religion or

 7     political commitment."

 8             MR. STRINGER:

 9        Q.   Mr. Hadzic, the visit of Branko Kostic to Borovo Selo just two

10     days before the JNA operation at Dalj was no coincidence, was it?  This

11     visit is linked together with the statements you have made publicly about

12     a Serb uprising, your trip to see Mandaric.  This is all part of the

13     events taking place just in advance of the Serb -- sorry, the JNA attack

14     on Dalj.  Isn't that true?

15        A.   I will limit myself to saying no.  To be polite.

16        Q.   You came back to Borovo Selo to accompany Mr. Kostic at this

17     event, didn't you?

18        A.   Where do you mean, I came back from?

19        Q.   I believe earlier in your testimony you indicated that you

20     weren't spending a lot of time in the SBWS or in Croatia.  You were

21     spending most of your time in Serbia but that you came back specifically

22     because of this.

23        A.   I heard in the interpretation "came back."

24             Yes, I came there because I knew Branko Kostic would be visiting.

25             MR. STRINGER:  Mr. President, I'm ready to move on to another


Page 10502

 1     topic, but if I could suggest breaking a few minutes early because it's

 2     going to be somewhat involved.  Not good to start.

 3             JUDGE DELVOIE:  No problem, Mr. Stringer.  We will adjourn for

 4     the day and come back tomorrow morning at 9.00.

 5             Mr. Hadzic, still under oath.  Thank you.

 6             Court adjourned.

 7                            --- Whereupon the hearing adjourned at 1.52 p.m.,

 8                           to be reconvened on Wednesday, the 27th day of

 9                           August, 2014, at 9.00 a.m.

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